A unanimous federal appeals court on Tuesday upheld a lower court’s preliminary injunction blocking the Trump administration’s 2025 immigration enforcement policy at certain houses of worship, ruling that the policy likely violated federal religious freedom protections.
The 4th U.S. Circuit Court of Appeals affirmed a February 2025 order by U.S. District Judge Theodore D. Chuang, an appointee of former President Barack Obama, which required the Department of Homeland Security to adhere to Biden-era safeguards when immigration officers operated near or at houses of worship. The appeals court’s decision applies narrowly to the plaintiffs in the ongoing litigation, including Quaker organizations, the Sikh Temple Sacramento, and the Cooperative Baptist Fellowship.
Court cites ‘irreparable injury’ to worship attendance
In a 40-page decision, Senior Judge Barbara Milano Keenan wrote that the plaintiffs presented evidence showing the Trump administration’s policy had caused a ‘reduction in attendance’ at their houses of worship. The court found that even temporary burdens on religious exercise constituted irreparable harm.
The 2025 policy, announced at the start of President Donald Trump’s second term, replaced a Biden-era directive that generally discouraged immigration enforcement at protected areas, including churches, schools, and hospitals. The new guidance instructed immigration officers to use their discretion and apply a “healthy dose of common sense” when conducting operations near these sites.
Plaintiffs allege policy creates ‘chilling effect’
The plaintiffs argued that the policy’s implementation had already led to declines in attendance among their congregations, citing fear of arrests and deportations within immigrant communities. Judge Keenan, joined by Judges G. Steven Agee (a George W. Bush appointee) and Pamela Harris (an Obama appointee), agreed that the policy imposed a ‘substantial burden’ on the plaintiffs’ ability to practice their faith through communal worship.
The dispute traces back to the early days of Trump’s second term, when the Department of Homeland Security rolled back protections established under the Biden administration. The new policy removed prior restrictions on enforcement actions at or near sensitive locations, leaving officers to determine when and where to conduct operations.
Policy’s scope and ongoing litigation
The appeals court’s ruling applies only to the named plaintiffs in the case, meaning the broader policy remains in effect for other locations. The litigation is ongoing, and the preliminary injunction will remain in place while the case proceeds. Legal experts note that the decision could influence future challenges to immigration enforcement practices near religious sites.